Liability for violating the requirements for registering employment contracts in the Unified System for Recording Employment Contracts (USREC) has been introduced in Kazakhstan

Photographic portrait of Dinara Tanasheva
Dinara Tanasheva

EY Partner, Tax & Law Leader for Kazakshtan and Central Asia

21 Jan 2026
Subject Tax & Law Alerts
Categories Law
Jurisdictions Kazakhstan

At the beginning of January 2026, the President of Kazakhstan signed a law on amendments and additions to the Code of Administrative Violations (Law of January 9, 2026, No. 257-VIII), introducing, among other things, administrative liability for violating the rules for submitting information on employment contracts in the Unified System for Recording Employment Contracts (hereinafter referred to as “USREC”).

I. Title of the respective article of the CoAV has been changed

The title of Article 98 of Code of the Republic of Kazakhstan on Administrative Violations dated July 5, 2014, No. 235-V (hereinafter referred to as the “CoAV”) has been changed to “Violation of the legislation of the Republic of Kazakhstan in the field of the population’s employment, as well as the procedure for entering information into the unified system for recording employment contracts.”

II. The composition of violations with corresponding penalties has been introduced

Article 98 of the CoAV has been added with parts 1-1 and 2-1 establishing the following violations and respective penalties (sanctions):

Violation

Penalties

Violation by an employer of the procedure for entering information on concluding and terminating an employment contract with an employee, amendments, and/or additions to it into the USREC, committed in the form of:

  1. failure to enter information or late entry of information into the USREC within the established deadlines;
  2. failure to enter information in full into the USREC;
  3. entering inaccurate and/or incorrect information into the USREC1

 

Fine on

  • officials in the amount of 30 monthly calculation indexes2 (“MCI”) (KZT 129,750)
  • small-size business entities or non-commercial organisations of 60 MCI (KZT 259,500)
  • medium-size business entities of 80 MCI (KZT 346,000)
  • large-size business entities of 150 MCI (KZT 648,750)

An action (inaction) committed repeatedly within a year after the imposition of an administrative penalty3

Fine on

  • officials in the amount of 60 MCI  (KZT 259,500)
  • small-size business entities or non-commercial organisations of 80 MCI (KZT 346,000)
  • medium-size business entities of 100 MCI (KZT 432,500)
  • large-size business entities of 200 MCI (KZT 865,000)

Important:

The above-mentioned amendments come into effect on 12 March 2026.

III. Possible risks

Inspections by the state labour inspection bodies, including at the request of employees.

IV. Recommendations for employers

In light of the above, it would be recommended for employers to:

  1. Conduct audit of the current situation with employment contracts and all the information on them entered/uploaded to the USREC.
  2. Determine a person (if possible/necessary) responsible for entering/uploading on a daily basis information on employment contracts to the USREC, as well as update such information within procedure and deadline set by the legislation.
  3. Follow up the validity term of a digital electronic signature used for entering and work in the USREC.

Nota bene (for your information):

If you need expert support to participate (join) in labour issues, we are ready to provide you professional assistance and support.


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